The Supreme Court held that a premarital agreement provision waiving an award of attorney fees related to issues of child or spousal support is categorically prohibited by Iowa Code 596.5(2), and Iowa Code 596.5(1)(g) prohibits fee-shifting bar provisions as to child-custody issues.
The parties in this case executed a premarital agreement waiving the right to seek an award of attorney fees in the event of a dissolution of their marriage. During their dissolution proceeding, Wife requested an award of attorney fees arising from litigating issues of child custody, child support, and spousal support. The district court declined to award attorney fees, concluding that, in the absence of any articulated public policy of the state, it did not have authority to ignore the plain language of the parties’ premarital agreement. The court of appeals reversed, concluding that the waiver provision in the premarital agreement was unenforceable as to child-related issues because it violates public policy. The Supreme Court affirmed the court of appeals decision on its award of attorney fees for child-related issues but vacated the part of the decision regarding attorney fees for spousal support, holding that the premarital agreement was also unenforceable as to the spousal-support issues. View "Erpelding v. Erpelding" on Justia Law

The Supreme Court answered a question asked by the federal district court as to whether a defendant can raise a defense of qualified immunity to an individual’s claim for damages in violation of Iowa Const. art. I, 1 and 8.
The operator of an ATV was arrested then released based on the finding that his conduct was not prohibited by law. Thereafter, the ATV operator brought suit against the city and the police officers under article I, sections 1 and 8 of the Iowa Constitution. The case was removed to federal court, which granted summary judgment to Defendants. The federal district court then certified a question of law to the Supreme Court. The Supreme Court answered that a defendant who pleads and proves as an affirmative defense that the defendant exercised all due care to conform with the requirements of the law is entitled to qualified immunity on an individual’s claim for damages in violation of article I, sections 1 and 8 of the Iowa Constitution. View "Baldwin v. City of Estherville, Iowa" on Justia Law

The Supreme Court held that Division I of Senate File 471 (the Act), which creates new prerequisites for physicians performing an abortion, violates both the due process and equal protection clauses of the Iowa Constitution because its restrictions on women are not narrowly tailored to serve a compelling interest of the State.
The district court held that the Act, which includes a mandatory seventy-two-hour waiting period between informational and procedure appointments, did not violate the Iowa Constitution. The Supreme Court reversed, holding that the “seventy-two hour[]” waiting requirement of the Act violates the right to equal protection and due process under the Iowa Constitution. View "Planned Parenthood of the Heartland v. Reynolds ex rel. State" on Justia Law

The conduct of an attorney who was removed by order of the district court from his elected position as Van Buren County Attorney, while deserving of disapproval, did not rise to the level of misconduct that would warrant the “drastic” remedy of a court order removing an elected official from office.
The Supreme Court reversed the judgment of the district court and vacated the order removing Defendant from the office of county attorney, holding that the State’s evidence was insufficient to meet the high bar necessary for the removal of Defendant from his elected office. The Supreme Court remanded the case for entry of an order reinstating Defendant as Van Buren County Attorney. View "State v. Watkins" on Justia Law

At issue was whether the three-year statute of limitations in Iowa Code 822.3 applies where a postconviction relief (PCR) petitioner files an untimely second petition for PCR alleging that counsel for his timely filed first petition for PCR was ineffective.
The district court concluded that the second petition’s allegations of ineffective assistance of postconviction counsel were not grounds to avoid the three-year statutory bar. The court of appeals affirmed, citing the Supreme Court’s decision in Dible v. State, 557 N.W.2d 881, 883, 886 (Iowa 1996).
The Supreme Court qualified Dible and held that where a PCR petition alleging ineffective assistance of trial counsel has been timely filed per section 822.3 and there is a successive PCR petition alleging that postconvcition counsel was ineffective in presenting the ineffective-assistance-of-trial-counsel claim, the timing of the filing of the second PCR petition relates back to the timing of the filing of the original PCR petition for purposes of Iowa Code section 822.3 if the successive PCR petition is filed promptly after the conclusion of the first PCR petition. The Court therefore vacated the court of appeals and reversed the decision of the district court and remanded the case. View "Allison v. State" on Justia Law

The Supreme Court adopted a tighter legal framework for warrantless inventory searches and seizures of automobiles under Iowa Const. art. I, 8 than provided under the recent precedents of the United States Supreme Court.
In his challenge to the search and seizure provision of article I, section 8 of the Iowa Constitution Defendant noted that a number of state courts have rejected the approach of the United States Supreme Court - which generally provides that warrantless inventory searches of automobiles are permissible if they are conducted pursuant to law enforcement policies that govern the decision to impound the vehicle and the nature and scope of any subsequent search - in favor of a more restrictive approach that sharply limits warrantless searches and seizures of automobiles.
The Supreme Court ultimately held (1) the police should advise the owner or operator of the vehicle of the options to impoundment, and when impoundment is necessary, personal items may be retrieved from the vehicle, and if the vehicle is impounded, containers found within the vehicle will not be opened but stored for safekeeping as a unit unless the owner or operator directs otherwise; and (2) the impoundment and search in this case was outside the bounds of any constitutionally permissible local impoundment and inventory policy. View "State v. Ingram" on Justia Law

The Supreme Court declined to hold that the felony-murder rule violates due process under the Iowa or United States Constitution when it is applied to juvenile offenders pursuant to a theory of aiding and abetting.
Defendant was a juvenile and unarmed when he participated in a marijuana robbery. A coparticipant, who had brought a gun to the crime, killed the robbery victim. Defendant was convicted of first-degree murder and sentenced to life imprisonment with immediate parole eligibility. The Supreme Court affirmed the conviction and sentence, holding (1) applying the felony-murder rule to juvenile offenders based on a theory of aiding and abetting is constitutional; (2) Defendant’s sentence did not constitute cruel and unusual punishment, either categorically or as applied to Defendant; (3) the trial court provided the jury with proper instructions regarding the types of assault required to establish the forcible felony robbery element of felony murder; and (4) the record was inadequate for the Court to address some of Defendant’s claims of ineffective assistance of counsel, and the remainder of Defendant’s ineffective assistance of counsel claims were without merit. View "State v. Harrison" on Justia Law

The Supreme Court declined to hold that the felony-murder rule violates due process under the Iowa or United States Constitution when it is applied to juvenile offenders pursuant to a theory of aiding and abetting.
Defendant was a juvenile and unarmed when he participated in a marijuana robbery. A coparticipant, who had brought a gun to the crime, killed the robbery victim. Defendant was convicted of first-degree murder and sentenced to life imprisonment with immediate parole eligibility. The Supreme Court affirmed the conviction and sentence, holding (1) applying the felony-murder rule to juvenile offenders based on a theory of aiding and abetting is constitutional; (2) Defendant’s sentence did not constitute cruel and unusual punishment, either categorically or as applied to Defendant; (3) the trial court provided the jury with proper instructions regarding the types of assault required to establish the forcible felony robbery element of felony murder; and (4) the record was inadequate for the Court to address some of Defendant’s claims of ineffective assistance of counsel, and the remainder of Defendant’s ineffective assistance of counsel claims were without merit. View "State v. Harrison" on Justia Law

Under the Iowa Constitution, a community caretaking seizure of a vehicle must be undertaken for genuine community caretaking purposes. In this case, a law enforcement officer was justified under the “community caretaking function” exception to the warrant requirement of the Fourth Amendment and Iowa Const. art. I, 8 when he pulled behind a vehicle stopped by the side of a highway after 1 a.m. with its brake lights engaged and activated his emergency lights.
Defendant was charged with operating while intoxicated, first offense. Defendant moved to suppress the evidence obtained as a result of the stop of his vehicle, arguing that the stop of his vehicle and person was unconstitutional. The trial court denied the motion. The Supreme Court affirmed, holding that the conduct of the deputy in this case was not unconstitutional because the officer acted out of a genuine community caretaking motivation. View "State v. Coffman" on Justia Law

Plaintiff could not prove the City discriminated against him because of his multiple sclerosis (MS) when the City was unaware he had MS.
Plaintiff applied for a full-time job as a firefighter with the City of Marion. The City denied Plaintiff’s application after a physician reported that Plaintiff was not medically qualified for the position, but the physician did not inform the City that MS was the reason Plaintiff was found unfit for firefighting. Plaintiff later sued the City and the physician’s employer under the Iowa Civil Rights Act (ICRA) alleging disability discrimination. The district court granted summary judgment for all defendants. The Supreme Court affirmed, holding (1) without any requested accommodation by Plaintiff, the City had no duty to second-guess the physician that Plaintiff was medically unqualified for the position; and (2) the physician was not liable for aiding and abetting the discrimination without proof that the City intentionally discriminated against Plaintiff. View "Deeds v. City of Marion, Iowa" on Justia Law